Judgment

RAGHUBAR DAYAL, J. : These are three petitions under Art. 32 by the petitioners, which is a partnership firm, praying for a declaration that S. 2 of the Madras General Sales Tax (Special Provisions) Act 1963 (Act No. 11 of 1963) hereinafter called the Act, is ultra vires the Constitution and of no effect and for a writ of mandamus directing the State of Madras to refrain from enforcing any of the provisions of that section. Each of the petitions relates to a particular assessment year.

2. The petitioners are dealers in skin carrying on business at Shenbakkam, Vellore, North Arcot District, in the State of Madras. They purchase raw skins from places both within and outside the State of Madras, tan the same and sell them through their agents in Madras. They were assessed to a certain amount of sales-tax, in accordance with the provision of the Madras General Sales Tax Act 1939 (Madras Act IX 1939) and R. 16(2) (ii) of the rules framed thereunder viz. the Madras General Sales Tax (Turnover and Assessment) Rules, on the turnover of hides and skins purchased in the untanned condition outside the State, but tanned within the State, with respect to each of the assessment years 1955